OFAC Published Maritime Sanctions Compliance Guide

OFAC is issuing an OFAC Compliance Communiqué: Sanctions Compliance Guidance for the Maritime Shipping Industry 

This scenario-based guidance is to aid maritime sector stakeholders in identifying certain new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance

Five scenarios are illustrated, 

1. Deceptive shipping practices to conceal sanctions nexus
2. Identification of Specially Designated National on trade documentation
3. Policy or registration renewals for vessels with obscured or complex ownership structures
4. Mid-voyage notification of sanctions risk
5. Opaque ownership information of proposed oil tanker purchaser

[October 31, 2024 Sanctions Guidance for the Maritime Shipping Industry. ]

This guidance supplements OFAC’s previously published guidance related to the maritime sector, including the May 14, 2020 Sanctions Advisory for the Maritime Industry, Energy and Metal Sectors, and Related Communities.

[May 14, 2020 Guidance to Address Illicit Shipping and Sanctions Evasion Practices]